United States v. Mead Corp., 533 U.S. 218 (2001), is a case decided by the United States Supreme Court that addressed the issue of when and where the Chevron Doctrine should be applied.
Video United States v. Mead Corp.
Background
Mead Corporation challenged a ruling of the United States Customs Service classifying its day planners as "diaries, notebooks and address books, bound," which were subject to a tariff.
Maps United States v. Mead Corp.
Issue
Before Mead, it was clear that the Chevron Doctrine applied to interpretations adopted in legislative rules and certain formal adjudications, but lower courts differed regarding whether it also applied to interpretative rules, policy statements, informal adjudications, advisory letters, amicus briefs. Finally, in 2001 the Supreme Court began to shed some light on the issue.
In Mead, it was questioned whether the court should defer to the U.S. Customs Services interpretation of the Customs Act, as manifested through the many classification decisions its regional offices made annually. The Court granted certiorari to determine the limits of Chevron deference.
Decision
The Court, speaking through Justice Souter, held that "administrative implementation of a particular statutory provision qualifies for Chevron deference when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law, and that the agency interpretation claiming deference was promulgated in the exercise of that authority."
Recognizing that thousands of tariff decisions are issued each year by the 46 regional offices of the U.S. Customs Service, and that each decision has no precedential value, the court determined that the Chevron Doctrine should not apply.
However, the Court remanded the case for the Court of Appeals for the Federal Circuit to determine whether Customs' classification decision was entitled to deference according to its "power to persuade" under Skidmore v. Swift, 323 U.S. 134 (1944).
Dissent
Justice Scalia was the sole dissenter in the case. Scalia believed that Chevron deference should be applied to all agency decisions that are "authoritative," and thus took issue with the Court's reaffirmation of Skidmore, which Scalia called an "anachronism".
See also
- Chevron v. Natural Resources Defense Council
- United States v. Haggar Apparel Co., holding that the Court of International Trade was required to apply Chevron deference to regulations promulgated by the Customs Service.
- List of United States Supreme Court cases, volume 533
- List of United States Supreme Court cases
References
External links
- Text of United States v. Mead Corp., 533 U.S. 218 (2001) is available from: Findlaw Justia
- Summary of case from OYEZ
Source of article : Wikipedia
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